IR 05000346/1985035

Insp Rept 50-346/85-35 on 851112-1206.Violation Noted: Bechtel Engineering Evaluations for Util Site QC Issued Nonconformance Repts for Pipe Anchors Utilizing Methods Other than Stress Allowable Criteria in Procedure

ML20138R434
Person / Time
Site:	Davis Besse
Issue date:	12/27/1985
From:	Danielson D, Fair J, Yin I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20138R425	List: IR 05000346/1985035 ML20138R422 ML20138R431
References
50-346-85-35, IEB-79-07, IEB-79-7, NUDOCS 8512310281
Download: ML20138R434 (18)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

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Report No. 50-346/85035(DRS)

Docket No. 50-346 License No. NPF-3 Licensee: Toledo Edison Company Edison Plaza 300 Madison Avenue Toledo, OH 43652 Facility Name: Davis-Besse Nuclear Power Station, Unit 1 Inspection At: Bechtel Power Corporation, Gaithersburg, MD (Bechtel)

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Davis-Besse Site, Oak Harbor, OH ,

Inspection Conducted: November 12-14 and December 4-6, 1985 at Bechtel

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November 19-21, 1985 at Site Inspector- I. T. Yin / 7?!Y Date h

M J. R. Fair / 2.7 h~

[ (November 12-14, 1985 only) Date

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b Approved By: D. H. Danielson, Chief / 2 2.7//f Materials and Processes Section Date~

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Inspection Summary Inspection on November 12 through December 6, 1985 (Report No. 50-356/85035(DRS))

Areas Inspected: Special, announced inspection of the auxiliary feedwater pump turbine steam supply (AFPTSS) piping modifications, the Facility Change Request (FCR) system, implementation of Region III (RIII) Confirmatory Action Letter (CAL) 85-13 actions, engineering evaluctions for Nonconformance Reports (NCRs) issued as a result of the reinspection program, and followup on previous inspection findings. The inspection involved a total of 72 inspector-hours onsite and at the A-E's office by two NRC inspector Results: Of the areas inspected, one violation was identified: (failure to follow NCR evaluation procedure by Bechtel staff, Paragraph 5.c.(1)).

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0512310281 851227 PDR ADOCK 05000346 O PDR ,

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DETAILS 1. Persons Contacted

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Toledo Edison Company (TED)

• J. K. Wood, Nuclear Plant Systems Director

• J. F. Helle, Nuclear Facility Engineering Director t

• S. M. Quennoz, Group Director, Nuclear Engineering

• C. T. Daft, QA Director

• G. L. Lillman, Engineering Administration Supervisor

+*P. H. Straube, Senior Engineer

+*T. J. Bloom, Licensing Engineer

• S. G. Wideman, Senior Licensing Specialist

• • R. Kies, Nuclear Facility Engineering Manager

! S. J. Osting, Senior Assistant Engineer l C. C. Mekbel, Civil and Structural Systems Engineer 5. C. Jain, Senior Nuclear Engineer C. Ackerman, Engineer i

G. Tureson, Group Supervisor

R. Ackerman, Assistant Engineer M. Shepherd, Code Inspection Supervisor

M. Hurley, Mechanical QC Inspector D. Rhodes, QC Supervisor Bechtel Power Corporation (Bechtel)

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+ H. Franzen, Deputy Civil Group Supervisor *

C. H. Abutaa, Senior Engineer

• V. Marathe, Assistant Project Engineer T. A. Mckearney,. Material and Quality Services Manager

+0. L. Gill, Pro.iect Quality Engineer

• S. A. Bernsen, Manager of QA

+ J. Ray, Project Engineer

+ C. Lowery, Project QA Engineer

+J. M. Ogle, Civil Engineering Supervisor

• T. I. Gillespie, QA Manager, Projects

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M. Zucofski, Civil Engineer i

R. Lee, Engineering Supervisor

. M. S. Wasserman, Mechanical Engineering Supervisor

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N. Tolani, Stress Engineer l M. L. Murphy, Mechanical Engineer

, D. P. O'Reilly, Mechanical Engineer

] R. Zeigler, Civil Engineer i F. Hinzman, Civil Engineer

Stone and Webster Engineering Corporation J. Nicholson, Engineer

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, USNRC

• G. Rogers, Senior Resident Inspector

+ Denotes those attending the management exit meeting on November 4, 1985

at Bechte * Denotes those attending the management exit meeting on November 21, 1985

at sit ' Denotes those attending the management exit meeting on December 6, 1986

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at Bechte . Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (346/79-11-05): Licensee actions to service the snubber ball bushings that should not have been greased. A followup 1 inspection is documented in RIII Inspection Report No. 50-346/83-1 To date the licensee has replaced bushings on 63 snubbers. The work was prescribed in site Maintenance Work Order (MW0) 1-83-4626-00, issued on September 1, 1985, and signed off on February 5, 1985. The remaining affected bushings will be replaced and the grease fittings will be removed during regular snubber maintenance using site procedure MP 1410.02,

" Maintenance of Hydraulic Snubbers", Revision 4, dated October 24, 198 In addition, ball bushings that are found to be stiff or tight will be i reworked as soon as they are identifie (Closed) Unresolved Item (346/83-17-01): Some of the small bore pipe supports with complex configurations were improperly designed using cookbook type methods. TED identified a total of 806 non-standard

small bore pipe supports, among which 724 required calculations to determine adequacy. As a result of the evaluations, 49 supports were

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modified and 2 were deleted. The inspector reviewed the following work packages and had no adverse comments: ,

• TED FCR 85-0176, dated September 14, 1985 incluoing Supplement 1,

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dated September 18, 1985 and Supplenent 2, dated September 25, 198 * TED NCR 85-096, dated August 29,.1985 including Addendum 1, dated October 16, 198 (0 pen) Unresolved Item (346/83-17-02): During the NRC inspector's previous observation of small bore piping suspension systems, unusual arrangement conditions were identified- The licensee stated that they

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would evaluate the generic effects of small bore support / restraint j

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interactions between snubbers, loose guides, tight guides, rigid restraints, and rigid supports. The NRC inspector reviewed the TED

, evaluation and indicated additional clarification was required to resolve this matter.

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(Closed) Unresolved Item (346/83-17-03): The functionability of snubber No. 30-GCC-8-H8 was questionable since it was installed close to rigid restraint No. 30-GCC-8-H7. The inspector reviewed Teledyne Engineering Services report TR-5639-2, " Analysis and Evaluation of the Safety / Relief Valve Discharge System Per NRC NUREG 0737", Revision 0, dated January 1983 end observed the design loading for the strut to be 1440 pounds and for the snubber to be only 371 pounds. The thermal displacement at the common location was 0.009". The licensee's technical staff stated that snubber No. 30-GCC-8-H8 will be replaced by a rigid sway strut during the next refueling outag (0 pen) Unresolved Item (346/83-17-04): Several new vintage ITT-G hydraulic snubbers with Miller cylinders, including PSP-1-H4 and PSP-1-H6 installed on Pressurizer Spray Piping System, were observed without fluid reservoir breather and filter unit There are both the new type and old type ITT-G snubbers installed in the plant systems. The new type comes with an air filter installed on the fluid reservoi Some of these filters were observed to have been replaced by the old type snubber reservior plugs with a small drilled hol The NRC inspector emphasized that equipment should be restored to its original design conditio (Closed) Unresolved Item (346/84-28-11): Snubber No. PSU-H1 installed on the 10" pressurizer surge line was found broken at the piston rod. The inspector reviewed the licensee's corrective actions stated in a letter to RIII (No. 1-494), dated January 18, 1985 including: (1) calculations to demonstrate postulated failure mechanism, (2) calculations to demonstrate the adaquacy of the Nuclear Class 1 stanchion to pipe weld, and (3) reinspection of pressurizer surge line restraints and surrounding areas to assure adequate clearance. The inspector stated that he had no further questions regarding the matte (Closed) Unresolved Item (346/85033-01): Design concerns raised by the NRC inspector during pipe walkdown included adequate modeling of rigid pipe whip restraints (WRs) and penetration anchors in piping stress analyses and adequacy of hanger location (HL) drawings to record all seismic restraints. During the inspection conducted at Bechtel, the NRC inspector reviewed:

• Stress isometric drawing M-233E, Revision 5, dated November 6, 198 * Computer output for stress problem No. T-004(lb)(02), "High Pressure Injection System Run", dated June 24, 198 ,

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Both drawing M-233E, and stress problem T-004 showed correct WR and penetration location To ensure that HL drawings will include WR locations and to re-verify the piping system dimensional measurements, the licensee revised TED Nuclear Facility Engineering Procedure (NFEP) No. IP-M-002, "The Piping Support Inspection and Verification Program: Verification of Support /

Component Location and Quantity". Revision 1, dated November 9, 198 The revised procedure included provisions for piping dimensional measurements, documentation, and engineering evaluation for deviation . .

3. Licensee Actions on IE Bulletins (Closed) IE Bulletin 79-07 (331/79-07-88): " Seismic Stress Analysis of Safety-Related Piping," dated April 14, 1979. The NRC inspector reviewed the following documentation:

• TED letter to RIII, Serial No. 1-62, dated April 24, 197 * Babcock and Wilcox (B&W) letter to TED, 08-79-25, dated April 23, 197 * Bechtel letter to TED, BT:8723, dated April 23, 197 As a result of the investigations conducted by B&W and Bechtel, piping analysis computer programs were found not to use algebraic summation (with predicted loads in the negative direction offsetting predicted loads in the positive direction) of the seismic loads in either horizontal or vertical direction Based on these investigations, no further action was require . TED Implementation of RIII CAL Action Items CAL 85-03 (Ciosed)

RIII Inspection Report No. 50-346/85013, Paragraph 10, documented closeout for CAL 85-03 Items 1, 2, 4, and 5. Item 3 involved an inservice testing program for the AFPTSS piping system to determine the cause and the nature of the system transient that resulted in degradation of pipe restraints. Since the AFPTSS system has been -

modified extensively (see Paragraph 6), the lica aee made a request to RIII in a letter (Serial No. 1-569, dated September 10, 1985) to delete CAL 85-03 Item 3. To replace the above testing, TED agreed to conduct confirmatory tests on the AFPfSS piping system following the completion of system modification and prior to Mode 3 operatio RIII concurred with the licensee's request. Followup of TED confirmatory test program is planned. This is an Open Item (346/85035-01). CAL 85-13 (0 pen)

As a result of a meeting conducted at the site on October 9, 1985 (RIII Inspection Report No. 50-346/85033, Paragraph 4) RIII CAL 85-13 was issued on October 17, 198 The licensee implementation of the CAL was reviewed by the NRC inspector. The status of CAL Item 1 (action items prior to plant restart) is as follows:

Item 1.a(1)(Oped 2,365 pipe supports will require reinspection prior to restar The reinspection status as of December 4, 1985, is as follows:

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Reinspections

• All 2365 hangers had been inspected

• 2152 NCRs were issued Engineering Evaluation of NCRs

• 659 NCRs were determined to be "Use-As-Is"

• 172 NCRs required corrective actions Item 1.a(2) (0 pen)

Upon completion of Item 1.a(1), all the new NCRs that require rework and approximately 250 old NCRs which could affect system safety will be forwarded to Bechtel for system operability evaluatio The Bechtel evaluation is to be based on TED procedure NFEP-060,

" Processing NCRs, SDRs, and SDDRs", Revision 4, dated October 22, 1985, Exhibit X, " Program for Conducting Seismic Category I Piping System Operability Evaluations and Use of Interim Allowables at Davis-Beste Nuclear Power Station Unit No. 1". The NRC inspector reviewed the above program and considered the provisions to be appropriate and adequat Item 1.a(3) (Closed)

The procedural provision for screening any NCRs for safety-related piping system supports inside containment not listed in Item 1.b but determined to be significant relative to system operability is included in TED procedure NFEP-060, Exhibit X (refer to Item 1.a(2)

above). The NRC inspector's review of the TED disposition of NCRs generated as a result of the reinspection program concluded that the licensee actions taken were adequat Item 1.a(4) (0 pen)

The FCRs that could impact safety-related piping system operability include:

General Description Status FCR N (No. of Supports Involved) (As of 12/05/85)77-213 Install time meters (3) Work in progress77-398 ! solation valve and bypass valves (6) Work in progress78-126 Upgrading 4"-ERD-61 (138) Work completed, in closcout 78-360 Redirect discharge RC769 (5) Work in progress 79"421 AFW pump turbine modification (15) Work completed, in closcout

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.80-276 Instail seal return line (13) Work completed, in closeout 80-221 Change relief setpoint (3) Work in progress83-136 Replace FW pump governor (2) Work in progress83-138 Change of 14 valves (4) Work in progress83-151 SWS valve modification (2) Work in progress85-025 Motor driven FW pump (103) Work in progress85-086 Modify Support 3A-EBD-19-H147 (1) Work completed, in closecut 85-010 Modify Support GC-EBD-4-H11 (1) Work in progress85-126 Floodwall penetration - Plan in development Roon 237 (3)85-143 Relocate steam admission Work in progress valves (6)85-163 Install one pipe whip Work in progress restraint (1)85-160 PORV loop seal drain (8) Work in progress85-176 Small bore pipe support Work in progress modification (51)85-224 Add snubber to MSSV 2 (1) Plan in development Item 1.a(5) (0 pen)

TED will provide RIII a summary report in sufficient advance prior to plant restart (presently scheduled for February 1986), to document: (1) reinspection findings and subsequent evaluations, (2) resolution of adverse findings that required rework, and (3)

basis for not performing inspections /walkdowns and resolution of resulting NCRs for all safety related piping system supports not listed in Item . Review of TED NCR Evaluatiens Review of NCR Packages In conjunction with RIII Inspection Report No. 50-346/85033 Paragraph 5, the NRC inspectors selected the following TED NCR evaluations and dispositions for review at Bechtel and at the site:

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Hanger No. and NCR. N (Load in Lbs, and Inspector's (Systcm) Ft-lbs, and Direction Nonconformance(s) Comments 85-0256 A-47 Undersize weld See Paragraph (HPI) (232 Fx, 231 Fy, on pipe saddle 5.C.(1)

408 Fz, 200 Mx, 1285 My, and 1787 Mz)

85-0254 A-46 Undersize weld See Paragraph (HPI) (158 Fx, 725 Fy, on pipe saddle 5.C.(1)

237 Fz, 6861, Mx, 473 My, 878 Mz)

85-0598 34-HCB-9-H10 * Weld not all Bechtel Calcu-(CS) (large bore pipe around per lation N Fx and 1208 Fy; design 190-6, Rev. 1 small bore pipe e seam weld in dated 10/25/85 100 design) lieu of fillet was acceptable

• violation of bolt distance 85-0365 33C-HCC-91-H9 Missing and Bechtel Calcu-(HPI) (300 Fx, 300 Fy) undersize welds lation No. 560-01, Rev O, dated 9/25/85 was acceptable 85-0277 33C-CCB-2-H25 * Notch found on Bcchtel Calcu-(HPI) (500 Fx and 900 Fy) beam flange latior. No. 56A-03,

• Missing and Rev. 1, dated undersize welds 9/23/85 was accepteble 85-0443 338-GCB-10-H6 * Excessive base Bechte! Calcu-(LPI) (1358 Fy) plate gaps lation No. 18F-06,

• Weld design Rev. O, dated deficiency 10/7/85 was

• Restrictive acceptable strut bushing movement

• Staked threads on U-bolt 85-0696 33A-GCB-8-H8 * No base plate Bechtel Calcu-(DHR) (1496 Fy) bearing shims lation No. 328-15,

• undersi;e welds Rev. 1, dated 10/10/85 was acceptable

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85-0442 338-GCB-10-H9 * Welding deviated * TED Calculation (LPI) (680 Fy) from design No. C-ME-49.02-006, dated 9/28/85 was acceptable

• Missing lock nut * Acceptable

• Strut bushing * Acceptable not moveable by hands

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85-0662 33C-HCB-9-H14 * Stripped jam nut * Acceptable (LPI) (1796 Fx) on anchor bolt

• Missing Lock nut * Acceptable on clamp

• Shim weld on * Acceptable clamp 85-0355 33C-CCB-2-H17 Weld and struct- TED Calculation (HPI) (354-FZ) ural member No. C-ME-52.01-033, configuration dated 10/22/85 deviated from was acceptable

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85-0581 41-HBC-35-H50 Excessive weld on Acceptable (SW) (700 Fx) support member 85-0283 6C-EBD-14-H8 * Clamp space * Acceptable (AFW) (1400 Fz) deviation

• Staked threads * Acceptable

• Hissing lock nut * Acceptable

• Weld deviation * TED Calculation No.C-ME-50.03-053, dated 10/22/85 was acceptable 85-0502 6C-E00-14-H21 * Loosened Strut * Tightening nuts (AFW) (1400 Fx) required Accept-able

• Pin-to pin * Acceptable not shown on drawing b. Verificotton of Support Design Loads A number of hanger loads documented in Rl!! Inspection Report No. 50-341/85033, Paragraph 5, and some of the hanger loads listed in Paragraph 5.a above were selected to verify that correct or conservative support design loads were used during NCR evaluation The following hanger loads were compared with the latest piping stress analysis computer output: )

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Hanger N Bechtel Piping Stress Analysis N FCB-2-H1 T-007(b), Rev. 1, dated 4/28/81 33C-CCB-2-H44 T-004(1b), Rev. 2, dated 8/7/80 33C-HCC-124-H4 56F, Rev. 1, dated 3/18/85 33C-CCB-2-H11 56A, Rev. 5, dated 3/18/85 33C-HCC-91-H10 560 Rev. 1, dated 11/8/72 338-GCB-10-li13 18F, Rev 2, dated 4/12/80 A-47 45A, dated 6/1/80 34-HBC-9-H10 190, dated 4/18/80 33C-HCC-91-H9 560, dated 11/8/72 33C-CCB-2-H25 56A, dated 6/1/30 338-GCB-10-H6 18F, dated 4/12/80 33A-GCB-8-H8 328, dated 12/13/79 No deficiencies were identified as a result of the review /

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verification.

c. Inspection Findings (1) Procedure Implementation The NRC inspector reviewed Bechtel Calculations No. 1-46, Volume R-1, Revision 8, dated August 25, 1985 for NCR No. 85-0254, and No. A-47, Volume R-1, Revision 5, dated September 26, 1985 for NCR No. 85-0256 and concluded that the allowable stress criteria prescribed in the Bechtel evaluation proceduro MGP-04, " Procedure for Control of Interim /Short Term Allowable Stress Criteria for Seismic Catcogry I Piping Systems",

Revision 1, dated September 27, 1985 were not utilized. The MGP-04, Table 1, " Design Criteria", Section 3.3.(b), set SSE stress allowable for ASME welds at 0.3 Sy. To the contrary:

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• The allowable stress for the weld attachment to pipe for NCR No. 85-0254 used the criteria from Section NF of the ASME Code which set through wall tension of 0.3 Sy, base material shear of 0.4 Sy, and weld throat of 21 ksi to be stress allowable * The allowable stress for the weld attachment to pipe for NCR No. 85-0256 considered only base material shear and used 0.4 Sy as stress allowabl Af ter corrections were made to the calculations, the af fected supports weret still within the procedural stress allowables. In review of HGP-04, certain clarification was determined to be helpful for future review understanding. The failure to follow the approved procedure is a violation of 10 CFR 50, Appendix 0, Criterion V requirements (346/85035-02).

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(2) Minimum Weld Size The present NCR evaluation for weld deficiencies designed to AISC specification (7th Edition) did not include AWS D criteria for minimum weld sizes corresponding to base material ,

thicknesses. During a discussion at Bechtel on November 14, 1985, the licensee stated that they will provide either specific case by case or generic / worst case metallurgical evaluations for accepting weld design deviations from the AWS minimum weld size requirement. This is an unresolved item ,

(346/85035-03).

6. AFPTSS System Modification The AFPTSS system excessive steam condensation caused (1) support damage due to Ifne vibration, and (2) the pump to trip due to condensate flashing l to steam at the Terry turbine thus causing it to overspeed. These problems are discussed in RIII Inspection Report No. 50-346/8501 To minimize condensation build up, the admission valves for the steam turbines (several hundred feet away from the turbine) were relocated to a short distance from the turbine inlet nozzles. The system modifica-tion includes: (1) addition of two pneumatically operated isolation valves for the two turbines (Valve HV 5889A to be installed approximately 14 feet from Turbine 1-1 nozzle, and Valve llV 58898 approximately 5 feet from Turbine 1-2), and (2) open up isolation valves 106A and 107A on the l

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two crossover legs during normal plant operation. The system modification requires: (1) installation of high pressure steam traps, (2) a high energy line break (HELD) analysis, (3) equipment qualification (EQ)

, stuales for adverse operating environmental conditions, (4) pipe support, WR, and conduit support modifications, and (5) replacement of pressure switches.

' Review of FCRs The NRC Inspector reviewed the TED proposed system changes documented in the following FCRs, and had no adverse comments. The need for TED to improve its control of FCRs and the associated HW0s, is discussed in Paragraph * FCR-0143, " Relocation of AFPT Main Stream Admission Valves",

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dated September 18, 1985; Revision A, dated October 1, 1985, and Revision 0, dated October 10, 198 Supplement 1, dated September 18, 1985: redesign of piping (Dechtel letter to TED, No. BT-15691, dated September 12,1985).

Supplement 2, dated September 25, 1985: redesign of electrical system (Dechtel letter to TED, No. BT 15692, dated September 14, 1985).

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Supplement 3, dated October 2, 1985: (1) installation of new

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pneumatic operated isolation valves, (2) installation of new

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hangers, (3) modification of existing hangers, and (4) relocation and replacement of pressure switches (Bechtel letter to TED, No. BT-15737, dated September 26, 1985).

Supplement 4, dated October 18, 1985: (1) revision on steam and feedwater rupture control system logic and (2) changes on pressure switch locations and mounting details (Bechtel letter to TED, No. BT-15792, dated October 10, 1985).

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Supplement 5, dated November 9, 1985: (1) revise steam trap

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data sheets, and (2) provide details for isolation barriers and

, cover plates on main steam control board (Bechtel letter to

) TED, No. BT-15878, dated October 29, 1985).

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• FCR 85-0163, " Installation of Pipe Whip Restraints and Jet

! Impingement Barriers on AFPTSS System", dated September 17, 1985; and Revision A, dated September 18, 198 Supplement 1, dated September 20, 1985: (1) WR details, (2)

reroute conduits, and (3) provide additional conduit supports (Bechtel letter to TED, No. BT-15690, dated September 12, 1985).

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! Supplement 2, dated September 20, 1985: provide design package

! for WR-32 construction (Bochtel letter to TED, No. BT-15712, dated September 19, 19d5).

Supplement 3, dated October 2, 1985: (1) provide details for pipe encapsulation construction, (2) provide details for rerouting conduits, and (3) provide design for new conduit supports (Bechtel letter to TED, dated September 26, 1985).

Supplement 4 dated October 7, 1985: (1) additional conduit reroute, and (2) additional conduit supports (Bechtel letter to TED, BT-15763, dated October 3, 1985).

Supplement 5, dated October 9, 1935: (1) additional conduit reroute, and (2) additional conduit supports (Bechtel letter to TED, BT-15767, dated October 4,1985).

The scope of the system modification will also include: (1)

updating P & ids, (2) system description in USAR, (3) revision to system surveillance, (4) updating the EQ material lists, (5)

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revisions in piping support and WR drawings, and (6) updating in-service inspection e _ _ - _ _ - - _ _ _ - _ _ _ - _ - _ _ _ _ _ - _ _ - _ _ -

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b. Condensate Removal Since the system modification involved filling the AFPTSS lines with non-moving steam, the condensate removal at high pressure was a design concern. During his review of the TED program, the NRC inspector noted that a total of 12 Yarway series 460 and series 515 steam traps (STs) will be utilized at various low points in the system. The STs were designed to provide continuous operation at pressure up to 1500 psig. The AFPTSS condensate will be piped to condensate storage. The NRC inspector reviewed the Yarway speciff-cation including design data and component selection charts and had no adverse comments.

I c. E_QEvaluation Modification of the AFPTSS system to resolve the condensate buildup up problem, resulted in the system being subjected to continuous pressurization during normal plant operation. TED contracted Impell Corporation, New York Regional Office, to perform environmental studies, including the effects to EQ during and after

, the HELB event. The following Impell reports were reviewed by l the NRC inspector:

• No. 02-1040-1334, " Evaluation of Environmental Conditions From l AFPTSS Line Rupture", Revision 0, dated November 8, 1985.

l * No. 02-1040-1335, " Evaluation of Equipment Qualification Concerns Associated with AFW Line Break Study", Revision 1, dated November 13, 198 The reports recommended pressure switches in the auxiliary feedwater l pump rooms No. 237 and No. 238 be replaced by environ.nentally qualified equivalents. The EQ reports were forwarded to NRC - NRR I in a TED letter, Serial No.1208, dated November 16, 1985. The NRC inspector stated that he hsd no further questions in this are d. Review of Pipina Stress Analysis (1) Scope of Piping Modification (a) Delete five stress analyses (Problem Nos. 40A, 400, 120F, 120G, and 120H). A new Problem 40A, Revision 2 replaced these five analyse (b) Problem 41A, the remaining piping stress analysis, was not change (c) Modification of pipe anchors:

• A-3 on Train 1-2, now M-1181-H6, a 3 way restrain * A-282 on Train 1-2, now M-1181-H1, a 2 way restrain .

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• A-309 on Train 1-2, now M-1181-H5, a 3 way restrain * A-310 on Train 1-1, now M-1181-H2, a 3 way restrain The modification retained the existing baseplates and portions of structural steel welded on the baseplate (d) To improve system operations, seven rigid restraints and snubbers were disconnected:

• EBB-2-H29 (y direction restraint)

• EBD-19-H117 (x direction restraint)

• EBD-19-H127 (z direction restraint)

• EBD-19-H145 (y direction restraint)

• EBD-19-H84 (x direction restraint)

• EBD-19-H143 (z direction snubber)

• EBD-19-H146 (x direction snubber)

(e) Modification of rigid restraints:

• EBD-19-H103 (x direction only, x and y before)

• EBD-19-H113 (x direction only, x and y before)

(f) Addition of supports:

• Restraint M-1181-H3 replaced EBD-19-H145

• Snubber M-1181-H4 replaced EBD-19-143 (g) Some piping rerouting and removal uf portions of piping including valves near Turbine 1- (2) Review of Analysis The NRC inspector reviewed the following Bechtel piping stress analysis:

(a) Problem 40A, " Main Steam", Revision D2, dated September 25, 198 Due to the volume of the documentation related to the analysis, particular attention was given by the NRC inspector to verify the accuracy of the piping configuration mode No deficiencies were identified as a result of the review. The disconnection of many rigid restraints resolved the NRC inspector's previous concern relative to possible high thermal lockup stresses that may exist between some of the closely spaced restraints. A maximum thermal stress of 17,871 psi was checked at data point No. 68 (a tee), which is comfortably below the Code allowable of 22,500 ps (b) Problem 41A, " Main Steam", Revision 5, dated August 20, 198 .

A maximum thermal stress of 21,722 psi was checked at data point No. 61 (an elbow). The NRC noted that this stress is close to the Code allowable stress of 22,500 psi, and suggested some system relief be provide e. Review of HELB Analysis (1) Scope of Piping Modification (a) Installation of one new W Design details were shown on Drawing Change Notice (DCN) C-628-3, dated September 19, 1985, for Bechtel Drawing No. 7749-C-628, Revision (b) Installation of one new pipe encapsulatio Design details were shown on DCN C-679-3, dated September 26, 1985, for Bechtel Drawing No. 7749-C-679, Revision 8.

l (c) Installation of one jet impingement shiel Design details l were shown on DCN C-679-2, dated September 19, 1985, for l Bechtel Drawing No. 7749-C-679, Revision (d) 16 conduits required rerouting to avoid direct jet impingement.

1 (e) 52 new conduit supports will be added to the existing l suspension system, among which some only require beefing up of the existing support (2) Design Basis l

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The NRC inspector reviewed the Davis-Besse 1 USAR, Section 3.6.2,

" Dynamic and Environmental Effects Protection Criteria",

Revision 0, dated July 1982 and Revision 3, dated July 198 Use of the NRC-NRR Standard Review Plan, Section 3.6.1, " Plant Design for Protection Against Postulated Piping Failures in Fluid Systems Outside Containment", and Section 3.6.2,

" Determination of Rupture Locations and Dynamic Effects Associated With the Postulated Rupture of Piping" was referenced

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in the USAR.

l (3) Review of Calculations

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The NRC inspector reviewed the following Bechtel component calculations, and had no adverse comments.

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• No. 8 File:F16, "FCR 85-165 Main Steam Line Pipe Whip Restraint WR-32," Revision 3, dated October 30, 1985.

* No. 10 F11e:F16 " Design of Pipe Encapsulation Device, l Problem No. 3,85-165", Revision 1, dated November 20, 1985.

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• No. 7 File:F16, " Design of Jet Impingement Barrier for Junction Box JT5811, Problem No. 1, FCR 85-163, Reference Drawing C-679", Revision 0, dated September 17, 198 (4) Review of Bechtel Design Control A number of unresolved matters relative to the Bechtel design control provisions for the HELB analysis and the associated component design were raise (a) The following design criteria are in desktop design guides and not in the design procedures:

• Pipe Break Protection, issued by Bechtel, San Francisco office in July 198 * Pipe Whip Details, issued without signoffs and dat (b) Pipe Whip Details, Paragraph 7, stated, "A pipe will hinge about the second elbow or the next fitting if it is beyond the hinge distance and there are no other rigid structures to cause the hinge." Engineering justification was not available to backup this statement. This statement is also in conflict with Pipe Break Protection, Paragraph B.1,

"Circumferential Break" design requirement (c) Design tables "High Energy Line Jet Impingement" developed by the civil engineering group, and " Critical Crack Jet Characteristics" developed by the mechanical engineering group, had not been reviewed and approved for generic application (d) The NRC inspector reviewed the determination of break points and had not adverse comments; however, measures did not appear to be established to carry out the design and review requiretrents systematicall (e) There appeared to be a lack of delegation of specific disciplinary responsibilities, and a description of coordinating task interfaces among the responsible departments (mechanical, civil, electrical, field walkdown, and etc.)

Due to the limited inspection time it is the NRC inspectors view that the Bechtel engineers were not given sufficient opportunity to address his concerns and to present all available evaluation and backup documentation. A followup inspection of the Bechtel design control for the HELB analysis and the associated component design is planned. This is an unresolved item (346/85035-04).

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7. Licensee Control of FCRs

' Review of Procedures The inspector reviewed the following TED and Bechtel FCR procedures including Maintenance Work Order (MWO) procedures for performing system modification:

• TED NFEP-010, " Processing Facility Change Requests",

Revision 4, dated October 15, 198 * TED Administrative Procedure AD1844.00, " Maintenance",

Revision 14, dated July 25, 198 * Bechtel EDPI-3.16-11, " Processing Facility Change Request",

Revision 7, dated August 29, 198 The NRC Inspector's Comments As a result of the (1) procedure review; (2) followup inspection for the AFPTSS modification involving review of FCRs 143 and 163; (3) review of licen,see's disposition of NCRs issued during hanger and component location reinspections, and (4) inquiry into the outstanding piping and pipe support FCRs required to be closed prior to plant restart, the NRC inspector considers the present licensee effort to improve plant system operability and reliability to be substantial. However, to ensure a continuation of the same degree of personnel attention, the inspector noted that the licensee should evaluate the following comments and consider revising the present MWO and FCR system provisions in the near futur (1) Contrary to the present requirement that QC inspections including witness and hold points be determined by the QC/ Code reviewer, the NRC inspector notes that all safety-related MWO work including installation of new hangers and WRs and modification, repair, and readjusting of any exiting supports should require mandatory QC inspection / verificatio (2) Contrary to the present requirement that QC inspections for hanger configuration including location, dimension, and orientation not be initiated until all work within the MWO has been completed, the NRC inspector notes that inspections for individual supports should be conducted in a timely manner, as soon as the installation or rework has been completed by the craf (3) The inspector notes that the FCR system should receive additional revision to improve its effectiveness. Consideration should include elements such as: (1) classification should be assigned denoting importance to system safe operation and license commitments, to improve personnel sensitivity in restoring equipment and components to the FSAR/USAR conditions; 17 . .-

(2) careful planning and scheduling of work prior to the issuance of an FCR to minimize the number of changes; (3)

subdivision where possible should be provided for FCRs for easier management and closeout, and (4) integration of formal project and QA technical and programmatic audits and -

surveillances into the FCR system to ensure effective program implementatio Due to the limited inspection time and plant management personnel availability, the matter will be discussed further during a future inspection. This is considered to be an open item (346/85035-05). Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which will involve some action on the part of the NRC or licensee or both. Two open items disclosed during the inspection are discussed in Paragraphs 4.a, and . Unresolved Items An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, an open item, a deviation, or a violatio Two unresolved items disclosed during this inspection are discussed in Paragraphs 5.c.(2), and 6.e.(4).

1 Exit Interview The NRC inspectors met with licensee representative (denoted in

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Paragraph 1) at the conclusion of each segment of the inspections. The inspectors summarized the scope and findings of the inspection. The inspectors also discussed the likely informational content of the inspection report with regard to documents reviewed by the inspectors during the inspection. The licensee representatives did not identify any such documents as proprietar .

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